Dividends paid by a China Trade Act corporation to a nonresident alien individual, foreign partnership, or foreign corporation are subject to withholding of tax at source under Sec. 1.1441-1. However, see paragraph (c) of Sec. 1.1441-4 for exemption applicable to dividends paid to residents of Formosa or Hong Kong. [T.D. 6908, 31 FR 16769, Dec. 31, 1966]
controlled foreign corporations